But just how far Giuliani will remain from the business remains unclear. His close childhood friend and former deputy mayor, Peter Powers, will take the helm as chairman of the security and consulting firm which has reportedly earned more than $100 million since it was formed shortly after 9/11. But Giuliani will keep his equity stake in the firm, which was worth $4.1 million last year. Giuliani also will remain a partner at Bracewell & Giuliani, the Houston-based law firm that paid him $1.2 million last year. So it looks like Giuliani left himself more than a little wiggle room to keep tabs on his business venture.

"Given that he still has a financial stake in Giuliani Partners and it's managed by his childhood friend, Rudy is not going to get away with covering up his ties to shady clients like the government of Qatar, the pharmaceutical industry, and Hugo Chavez."

And the hits just kept on coming Wednesday for Giuliani anyway. Hours after it was officially announced that he was stepping down, Vanity Fair published a mammoth Giuliani profile: "A Tale of Two Giulianis" that raised the question, among many others, of whether it was even legal for Rudy, the candidate, to be collecting any compensation from his consulting firm.

"These days Giuliani’s office sits mostly empty as he canvasses the country for money and votes in his bid to become the Republican nominee for president in 2008. Is he even still working for Giuliani Partners? It’s a relevant question, because if he isn’t—and, really, how could he be in these busy weeks of campaigning before the first Republican presidential primaries?—then he shouldn’t be drawing a salary from the firm. According to a former top Federal Election Commission official, that would be a breach of election law: the firm would in effect be making undeclared campaign contributions.

The answer, from Giuliani Partners C.E.O. Mike Hess, is that “Rudy is no longer involved in the day-to-day operations of Giuliani Partners. He maintains his ownership interest.” To the point of whether Giuliani is still earning money from Giuliani Partners, the answer seems a bit delphic, especially after a Washington Post article from October 30, in which Giuliani Partners spokeswoman Sunny Mindel described Giuliani as still working part-time for the company.

To anyone who has followed Giuliani’s meteoric rise in business, that dodge is unsurprising. There are, it seems, at least two Rudolph Giulianis. One is the crusading former U.S. attorney and 9/11-bedecked ex-mayor of New York, cloaked in the six core values prominently featured on Giuliani Partners’ Web site: Integrity. Optimism. Courage. Preparedness. Communication. Accountability.

The other Rudy Giuliani is the one who has brazenly built a business on his 9/11 fame. "